Privacy, by
design and default.

This Privacy Policy applies to:

• All interactions with Camino Strategy Group via our website, email, client onboarding, consulting engagements, or other communications
• Individuals whose information is submitted to Camino for lawful business purposes or due diligence
• Business partners, prospective clients, and referral contacts

This Policy does not apply to third-party vendors, referral networks, or software platforms that operate independently from Camino and are governed by their own privacy policies.

This Policy is issued in compliance with California Civil Code § 1798.100 et seq., and the California Constitution’s Right to Privacy (Article I, Section 1).

Camino collects minimal personal information, only where necessary to fulfill contractual, legal, or operational obligations.

We collect and process personal information only when:

• You have provided affirmative consent (e.g., filling out a form or scheduling a consultation)
• It is necessary to perform or prepare for a contractual agreement (e.g., consulting services)
• We are required to comply with a legal or regulatory obligation
• We have a legitimate business interest that does not override your privacy rights

We use personal information strictly for:

• Communicating with clients, partners, and prospective clients
• Delivering advisory and strategic services
• Maintaining compliance with contractual and legal requirements
• Protecting Camino’s legal interests, website, and infrastructure
• Managing internal operations such as invoicing, research, and reporting

We do not use personal information for automated decision-making, cross-context behavioral advertising, or resale.

Camino does not share personal information with unrelated third parties. Limited disclosures may occur under the following conditions:

• Vendors & processors: We may engage secure third-party platforms (e.g., Google Workspace, Zoom, CRM tools) to assist with communication, file storage, or business operations. These providers are bound by confidentiality agreements and required to comply with California privacy law.
• Legal disclosure: We may disclose data in response to lawful subpoenas, court orders, or regulatory inquiries, provided that we take reasonable steps to limit the scope of disclosure and, when permitted, notify the data subject.
• Corporate contingency: In the event of a merger, acquisition, or restructuring, personal information may be transferred subject to contractual assurances and confidentiality restrictions.

Camino does not sell, rent, license, or otherwise share your data with marketers, advertisers, data brokers, or lead generation companies.

If you are a California resident, you are entitled to the following rights under California Civil Code § 1798:

• Right to know: Request the categories and specific pieces of personal information we have collected.
• Right to delete: Request deletion of your personal information, subject to exceptions for data required by law, contract, or legitimate business operations.
• Right to correct: Request correction of inaccurate information we hold about you.
• Sensitive information: We do not collect sensitive personal information (SPI) as defined under CPRA.
• Non-discrimination: We will not deny services, charge different prices, or alter the quality of services if you choose to exercise your privacy rights.

To make a request, contact contact@caminostrategygroup.com with the subject line Privacy Rights Request. Identity verification is required. We do not act on unverifiable or excessive requests and may deny requests that conflict with professional or legal obligations.

We retain personal information only for as long as it is reasonably necessary to:

• Fulfill the purpose for which it was collected
• Meet legal, regulatory, or contractual obligations
• Defend against claims or audits

Data is stored in encrypted cloud environments and periodically reviewed for relevance. When data is no longer required, it is securely deleted or anonymized in accordance with NIST and industry standards.

Camino maintains commercially reasonable administrative, physical, and technical safeguards in accordance with the California Data Breach Notification Law (Civil Code §§ 1798.29, 1798.82) and best practices under the NIST Cybersecurity Framework.

Security measures include:

• Role-based access controls
• Multi-factor authentication
• Use of secure enterprise-grade platforms
• Regular review of user permissions and system logs

Limitation of liability: While we take strong precautions, no system can be guaranteed secure. By using our services or website, you acknowledge and accept that Camino Strategy Group is not liable for third-party cyber intrusions, force majeure events, or access resulting from user-side security negligence.

Nothing in this Privacy Policy shall be interpreted to waive any applicable privilege or confidentiality protections under state or federal law, including protections related to consulting work product, confidential business information, or non-disclosure agreements in force.

By using our website or engaging with Camino Strategy Group, you agree to indemnify and hold harmless Camino, its officers, affiliates, and contractors from any and all claims, liabilities, damages, or costs (including attorney’s fees) arising from:

• Misuse of information provided to Camino
• Misrepresentation of your identity or authority to submit data
• Violation of applicable laws through use of our services or communications

This clause is subject to the limitations imposed by California law.

We reserve the right to revise this Privacy Policy at any time, with updates reflected by the “Effective Date” posted above. In the event of material changes to how we collect or use personal information, we will provide a clear notice on our website and/or contact affected parties as appropriate.

For questions, access requests, or complaints related to this Privacy Policy or Camino’s data practices, please contact:

We are committed to resolving all concerns in accordance with California law and professional business practices.